Three weeks ago, when we first reported that Qatar had offered to pay the Clinton Foundation $1 million after a hacked Podesta email disclosed that the ambassador of Qatar “Would like to see WJC [William Jefferson Clinton] ‘for five minutes’ in NYC, to present $1 million check that Qatar promised for WJC’s birthday in 2011”, we said that in this particular case, the Clinton Foundation may also be in violation of State Department ethics codes.

As we said in early October, while this has been seen by critics of the Clinton Foundation as yet another instance of influence pandering and “pay-to-play”, this time there may actually be consequences for the Clinton Foundation: according to the State Department, the previously undisclosed donation suggests there may be an ethics violation by the foundation, even though the State of Qatar is shown on the foundation’s website as having given at least that amount. There is no date listed for the donation.

Underscoring the potential flagrant abuse of ethical guidelines if the Qatar payment is confirmed, Hillary Clinton promised the U.S. government that while she served as secretary of state the foundation would not accept new funding from foreign governments without seeking clearance from the State Department’s ethics office. The agreement was designed to dispel concerns that U.S. foreign policy could be swayed by donations to the foundation.

Of course, US foreign policy could be very easily swayed if Hillary accepted money and simply did not report it the receipt of such money.

However, and where things got awkward for Clinton, is that the State Department has said it cannot cite any instances of its ethics officials reviewing or approving new donations from foreign governments to the foundation while Clinton served as the country’s top diplomat from 2009 until 2013, confirming the foundation was in clear breach of its ethics agreement over the not immaterial donation of $1 million from a foreign state, which as Hillary herself also disclosed in another hacked Podesta email, is the primary supporter of the Islamic State.

“You would need to ask the Foundation whether there were additional matters that it should have submitted for State Department review,” the department said in a statement.

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Fast forward to today when overnight Reuters reported that the Clinton Foundation has confirmed it accepted a $1 million gift from Qatar while Hillary Clinton was U.S. secretary of state without informing the State Department, even though she had vouched to let the agency review new or significantly increased support from foreign governments.

Clinton signed an ethics agreement governing her family’s foundation in order to become secretary of state in 2009. The agreement was designed to increase transparency to avoid appearances that U.S. foreign policy could be swayed by wealthy donors. According to the agreement, if a new foreign government wished to donate or if an existing foreign-government donor, such as Qatar, wanted to “increase materially” its support of ongoing programs, Clinton promised that the State Department’s ethics official would be notified and given a chance to raise any concerns.

Alas, it now appears that the agreement was nothing more than a piece of paper to Hillary Clinton, who violated its terms on at least one occasion, and potentially on .

Clinton Foundation officials last month declined to confirm the Qatar donation. In response to additional questions, a foundation spokesman, Brian Cookstra, this week said that it accepted the $1 million gift from Qatar, but this did not amount to a “material increase” in the Gulf country’s support for the charity. Of course, only in the world of the Clintons is $1 million not a “material” increase. It is also a flat out lie. As we calculated in October, according to the Foundation’s own website, Qatar gave anywhere between $1 million and $5 million, so in the best case scenario the donation would be a rather material 20% increase to Qatar’s total. In the worst case, it would be 100%.

Cookstra declined to say whether Qatari officials received their requested meeting with Bill Clinton. Officials at Qatar’s embassy in Washington and in its Council of Ministers in the capital, Doha, declined to discuss the donation.

But while Qatar was obvious engaged in pay to play, what makes this instance even worse, is that Hillary and Bill were confident enough they could simply get away with it by never telling the State Department of the new influence money. According to Reuters, the State Department has said it has no record of the foundation submitting the Qatar gift for review, and that it was incumbent on the foundation to notify the department about donations that needed attention.

“Oversights”

Foundation officials told Reuters last year that they did not always comply with central provisions of the agreement with President Barack Obama’s administration, blaming oversights in some cases. At least eight other countries besides Qatar gave new or increased funding to the foundation, in most cases to fund its health project, without the State Department being informed, according to foundation and agency records. They include Algeria, which gave for the first time in 2010, and the United Kingdom, which nearly tripled its support for the foundation’s health project to $11.2 million between 2009 and 2012.

Foundation officials have said some of those donations, including Algeria, were oversights and should have been flagged, while others, such as the UK increase, did not qualify as material increases.

The foundation has declined to describe what sort of increase in funding by a foreign government would have triggered notification of the State Department for review. Cookstra said the agreement was designed to “allow foreign funding for critical Clinton Foundation programs” to continue without disruption.

And the punchline: The State Department said it has no record of being asked by the foundation to review any increases in support by a foreign government.

This means that not only was there an “oversight” by Hillary to report the Qatari $1 million, she did not report the receipt of any foreign money funneling into the Clinton Foundation at all!

Asked whether Qatar was funding a specific program at the foundation, Cookstra fell back to the Foundation’s usual response when challenged about conflicts of interest, and said the country supported the organization’s “overall humanitarian work.”

“Qatar continued supporting Clinton Foundation at equal or lower levels” compared with the country’s pre-2009 support, he said. He declined to say if Qatar gave any money during the first three years of Clinton’s four-year term at the State Department, or what its support before 2009 amounted to. In another email released by WikiLeaks, a former Clinton Foundation fundraiser said he raised more than $21 million in connection with Bill Clinton’s 65th birthday in 2011. It was not immediately clear how much of this was not reported to the State Department due to “oversights.”

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To summarize, due to an “oversight”, Hillary Clinton violated an ethics agreement she signed during her tenure as State Department, and “forgot” to notify the Department (which she headed) that her family’s foundation had received at least $1 million from Qatar, a state which alongside Saudi Arabia, she admitted provides “financial and logistic support to ISIL”; and also appears to have “forgotten” to notify the State Department on all other occasions when foreign countries were paying the Clinton Foundation to purchase political influence and clout.

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The Clinton Foundation has said it would no longer accept money from foreign governments if Clinton is elected president and would spin off those programs that are dependent on foreign governments. Because if Clinton is elected president, she would much rather move the “oversights” to the Oval Office, where all the influence that donations – such as Qatar’s – have purchased over the year, can finally be exercised.